The deadline passed Monday for comments to the U.S. Food and Drug Administration on the preventive controls for animal food rule issued under the Food Safety Modernization Act (FSMA), and the American Feed Industry Association (AFIA) submitted more than 100 pages of comments on what it describes as the most massive overhaul of animal food industry regulations since 1958. Nineteen regional and state feed associations also signed on to AFIA’s letter as a statement of their support. Although the organization was disappointed that the comment period had not been extended past March 31, AFIA was still “extremely satisfied with the comments generated,” said Richard Sellers, the group’s senior vice president of legislative and regulatory affairs. “If more time had been allotted, we would have ideally provided FDA with more examples of the overall impact of the proposal. However, given our time constraints, AFIA focused primarily on how this rule would impact the many varied segments of the industry,” he said. The organization’s comments focused mostly on the Current Good Manufacturing Practices (CGMPs), stating that they should be “more practical and less prescriptive.” AFIA wants assurance that the rule is dedicated to the animal food industry rather than the human food industry. “It is quite clear the majority of the proposed CGMP requirements come directly from the human food rule, and it has been left up to the feed industry to prove why the requirements are unnecessary as many do not relate to animal food in the slightest,” said Sellers. “A blatant example is where the proposed rule suggests ill employees can contaminate animal food, hence making the animal sick.” In relation to the time frames FDA offered for phasing in smaller businesses, AFIA recommended changing them to add an extra year to the implementation period for the preventive controls portion of the rule. Under this proposal, GMPs and preventive controls would be in place within two years for large firms, three years for small businesses and four years for very small businesses. The idea has already been positively viewed by FDA. “In many ways, that, I would say, makes sense,” Dan McChesney, director of FDA’s Office of Surveillance and Compliance, told Food Safety News last December. “If you look at the human food industry, what we’re asking them to do is implement just the preventive controls in one year, two years or three years. They’ve been implementing GMPs for many years already, so they don’t have to do that part.” Other requests in AFIA’s comments were to simplify terms and concepts used throughout the rule such as replacing “utensils” with “tools” or “sanitation” with “cleaning,” differentiating among various types of animal food facilities, and for FDA to “remove all HACCP references and requirements throughout the rule, including references to ‘hazards that are reasonably likely to occur’ and return to the statutory language of ‘known or reasonably foreseeable hazards,'” Sellers said. In another regulatory area, the Beer Institute and the American Malting Barley Association filed joint comments requesting that FDA exempt brewers from the rule. Their concern is about putting additional regulation on the byproducts of brewing. (Food Safety News published a separate story today about how Colorado brewers are pushing back against the proposed rules.) “For centuries, brewers, large and small, have disposed of their spent grain by giving or selling them to farmers and ranchers,” reads a statement from the Beer Institute. “This recycling process supports community green initiatives, but could end if this FDA rule is upheld. Instead, some brewers will be forced to throw away this valuable feed, a cheaper option than complying with the costly proposed regulations, which the Beer Institute estimates may cost a single brewery more than $13 million in one-time and reoccurring costs.” Others are also supporting the proposal for exemption. The National Milk Producers Federation filed comments that referenced and included support for the Beer Institute’s comments. And U.S. Rep. Chellie Pingree (D-ME) even brought up the issue at last week’s House appropriations hearing with FDA Commissioner Margaret Hamburg. She asked for evidence that a cow has become sick after eating spent grains and for the exemption to protect the brewer-farmer partnership. “It’s one of those examples of something where there is a reasonable solution that can be found,” Hamburg responded. “We certainly understand why it makes economic and sustainable agriculture sense. … I hope we can find a meaningful, viable solution.” FDA has stated its plans to publish revised language for the proposed rule on preventive controls for animal food early this summer, alongside the revised produce safety and preventive controls for human food rules. The final animal food rule is required to be published by Aug. 30, 2015.